Wednesday, September 12, 2012

Radioactive Iodine in Sludge May Contaminate Environment and Drinking Water

Majia here: This is another post covering Ret. Capt. Clyde Stagner's analyses of radiation contamination in the Phoenix area caused by the Palo Verde nuclear plant in Maricopa County, AZ.

Capt. Stagner is author of Hidden Tritium and has had a long, distinguished career, including military experience, monitoring radiation. Please see his most recent post.

Maricopa Association of Governments
Memorial Day, 2012

Dear Ladies and Gentlemen,

Phoenix
treats 250 million gallons of wastewater each day. More than 90% of
Phoenix 's waste water is
highly treated and reused for crops ,turf irrigation, and power generation.
Twenty billion gallons of sewage effluent is used annually as cooling water by
the Palo Verde Nuclear Generating Station (PVNGS) from Phoenix,
Scottsdale, Tempe,
Glendale, and
Tolleson, Az. The cooling water is transported approximately 37 miles by
pipeline from the Phoenix
91st av Wastewater Treatment Plant(WWTP) to the utility's Water Reclamation
Facility (WRF) located adjacent to the cooling towers of the generating station.

NRC requires PVNGS to control the quantity of contaminants from
the WRF influent prior to its use as cooling water. In 2006, the utility
sampled the influent weekly for a composite which yielded forty seven samples
with Iodine-131 concentrations ranging from 11 to 96 pCi/L. Wet samples of
sludge were obtained weekly from the WFR centrifuge with I-131 in all fifty
one samples and concentrations ranging from 351-2460 pCi/kg.

I-131 is a radioactive isotope with a half life of eight days. A
low dose is most damaging to children because high doses kill cancerous
thyroids. Perchlorates in drinking water, or food, with I-131 cause accumulative damage to the thyroid, especially in young children.

The use and disposal of wastewater and reclaimed water within
Maricopa
County is governed by the rules and
regulations of the Maricopa County Environmental Health Code, Chapter2, Section
1,Regulation 2. Subsection B of the code requires all releases of wastewater,
or reclaimed water, to be considered spills which must be reported to the
Maricopa County Environmental Services Department. Environmental nuisances are
defined in Arizona
Revised Statutes
.Maricopa County
,EHC, Chapter49-141-144. Maricopa County EHC Chapter 11 defines nuisances as:

6. The pollution or contamination of any domestic waters.

9. Water which contains deleterious or foreign substances

In 2010, the utility
found I-131 in 44 of 48 samples of WRF influent from the Phoenix 91st Av WWTP with concentrations ranging from 12pCi/L to 85 pCi/L(Table 8.00 Surface Water).
Forty six samples of wet sludge from the WRF centrifuge had oncentrations ranging
from 367to 2743 pCi/kg( Table 8.11 Sludge Sediment.

The Phoenix 2011 annual
Water Quality Report showed no monitoring for 1-131 in drinking water. A 2006 deduction
attributed the 1-131to pharmaceutical sources in
Phoenix.

The
Arizona department of Environmental Quality
(ADEQ), under the provisions of ARS Title 49-10 A,
shall (3) conduct research;(4) Provide information and advice on request of private persons,
and others and (10) Provide for the prevention and abatement of all water pollution
including that related to radiation. Under the provision of ARS Title 36-1692A, the
Department shall establish an environmental exposure risk assessment program which
shall:2. Provide for different strategies to reduce or prevent public health risk from
environmental exposure. Effluent generated from the 23 Av WWTP is used to irrigate
crops in the Roosevelt Irrigation District. Effluent from Chandler
and Mesa WWTPs
is used for irrigation on the Gila River Indian Reservation.

The Arizona
Department of Health Services is responsible for providing the names of certified laboratories
,capable of providing required laboratory tests on wastewater effluents or biosolids,
for entities licensed by the Arizona Department of Environmental Quality. Liquid
biosolids are essentially 94 to 97% water which can be removed to 30% remaining (Ref:40CFr
Part 503). Phoenix
liquid biosolids were cited as having a solids concentration ranging
from 12 to 14% (REF: WEFTEC .05). Phoenix WWTPS must dry sludge to 40 % solids to
meet the contract with the sludge haulers(Ref: Brown BearCorp.com). Digested
sludge is removed by contract hauler,SYNAGEO to local farms for agricultural land for
application Treated biosolids can be produced in cake, granular, pellet, or solid/ form.

There are two classes
of biosolids: Class A reduces bacteria and is typically dried and pasteurized; Class B
includes all sludge not classified as A. Both classes may contain radioactive waste (Ref:
The Free Encyclopedia Wikipedia). Treated effluent is discharged

Some of the effluent discharged into the Salt
River from the 23 Ave or 91stAve WWTPs may percolate into groundwater.
In addition to receiving
some groundwater, storm water flows into the 91 Ave WWTP. According to ADEQ there
were 124 biosolids land application sites registered in Arizona.

As of April 2011,the total number
of acres registered, the number of these that receive biosolids
annually, and solid,or slurry, and whether Class A or Class B is being applied to
Arizona agricultural
land has not been made available to the public by ADEQ(Ref: Biosolids
Land USE in Arizona ,Janick
F. Artiola,PHD,revised 4/11).

ADEQ published the
2124 "Permitted POTWS and TWTDS with Biosolids Disposal Requirement," with
an annual biosolids production of 74,141 dry tons. The
Phoenix 91st Ave. WWTP produced
41,025 dry tons with the 23 d Ave. WWTP producing the next largest amount of 8,692
dry tons. Maricopa
County produced 56,702
dry tons of biosolids. ADEQ did not include
the year date this biosolid production occurred.

According to ADEQ
's September 2003 publication, "Biosolids/Sewage Sludge Management
Program Description," all information, except confidential information, will be
available to the public by ADEQ.

On 28 April, an email
was sent to the Deputy Director, Work Program Div, ADEQ, requesting the wet tons
of biosolids produced for the same year annual production of dry tons were produced for
which no year was given. The Deputy Director referred the request to the Manager,
Water Quality Utility Field Service Unit, who replied they were not a POTWS or and
TWTDS and,"feel free to contact me at 602-771-4612." On April 30, the Manager emailed
citing confusion about the information request. An email to the Deputy Director on 13
May, 2012 again requested a response or notification if censorship was in effect at ADEQ.

ADEQ requires testing
of selected biosolid contents by licensed recipients: testing for radioactive content is
not included. Radiation Safety Engineering, Inc was certified on March 28, 2012 to test
for Iodine (EPA 901.1). Information can be released by the
Az. Dept. of Health Services
in accordance with the AZ. Public Records Act. Information can be released by the Dept.of
Health Services in accordance with the Az. Public Records Act.

General requirements,
or management practices, are needed to protect human health and the environment from
any reasonable anticipated adverse effect that may occur from any pollutant in the
bulk sewage sludge ( Ref: 40 CFR 503.0 (b) (2)). Nothing precludes a state from imposing
requirements, for the use or disposal of sewage sludge, more stringent than the
requirements of 40 CFR when necessary to protect public health and environment for the use or disposal of sludge ( Ref: 40 CFR 503.5).

The concentration of
1-131 discharged from secondary treatment system liquid waste, Phoenix
91st Ave
WWTP, to the circulatory water system of PVNGS is limited to 1 x 10^-6 uCi/ml which is
the NRC water effluent concentration applicable to public exposure( 10 CFR, Part
20, Appendix B, Table 2). PVNGS has continually met its responsibility, year
after year, in cleaning the Phoenix
91 st Ave WWTP secondary effluent of its high concentrations
of I-131.

How many WWTPs are discharging I-131into Phoenix,
Maricopa county, and the remainder of Arizona?Tritium also accompanies the I-131 in its transition from the
91st Ave WWTP,via
pipeline, to PVNGS.

Sincerely,
Clyde H. Stagner

cc

Water Services Dept.
Phoenix

Professor Doctor Majia
Nadesan

R4Allegation,Respource@nrc.gov

PREVIOUS POSTS ON RET-CAPT. STAGNER'S ANALYSES

Capt. Clyde Stagner's book, Hidden Tritium, can be found at Amazon.com

About Me

I am a Professor at a large public university. I study political economy and biopolitics (the politics of life). My interests are diverse but are broadly concerned with economic, social and environmental justice. I have published 5 books: Crisis Communication, Liberal Democracy and Ecological Sustainability: The Threat of Financial and Energy Complexes in the Twenty-First Century (2016); Fukusima and the Privatization of Risk (2013); Constructing Autism (2005); Governmentality, Biopower and Everyday Life (2008/2011); Governing Childhood (2010).
I also participated in an edited collection on Fukushima: Fukushima: Dispossession or Denuclearization (2014).